G.R. No. L-43453. January 31, 1985.
NATIONAL HOUSING CORPORATION, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, and PEDRO DE LA CRUZ, respondents.

FACTS

Private respondent Pedro de la Cruz was employed as a laborer by petitioner National Housing Corporation. He contracted Hansen’s disease (leprosy), which forced him to stop working in June 1972. The petitioner’s own Personnel Office assisted him in applying for sickness and disability benefits with the Social Security System following his discharge due to this ailment. De la Cruz subsequently filed a claim for compensation benefits under the Workmen’s Compensation Act.
The Workmen’s Compensation Commission found that the petitioner, despite due notice, failed to file the required Employer’s Report and a notice of controversion within the statutory period. Initially, a hearing referee dismissed the claim, finding no evidence that the ailment arose from or was aggravated by his work. However, upon review, the Commission reversed this dismissal and awarded compensation to de la Cruz.

ISSUE

The core issue is whether the Workmen’s Compensation Commission acquired jurisdiction over the petitioner and properly awarded compensation, given the petitioner’s claim of lack of notice and violation of due process.

RULING

The Supreme Court ruled for the private respondent and affirmed the Commission’s award. The legal logic rests on two key points: waiver of defenses due to procedural default and the compensability of the disease.
First, the petitioner was deemed to have waived its right to contest the claim. The Court upheld the Commission’s finding that the petitioner had been duly notified of the claim. This knowledge was evident from the fact that its Personnel Office assisted de la Cruz with his SSS benefits application after his discharge specifically for Hansen’s disease. Having failed to file a mandatory notice of controversion within the period prescribed by Section 45 of the Workmen’s Compensation Act, the petitioner lost its right to challenge the claim on any ground, including jurisdiction and compensability. This procedural default constitutes a constructive admission of compensability.
Second, on the merits, Hansen’s disease is compensable under the Act when acquired or aggravated in the course of employment. The Court found that de la Cruz was physically fit when hired, as evidenced by his pre-employment medical examination. The symptoms manifested during his employment as a laborer, a physically demanding job that could lower bodily resistance. Furthermore, the workplace location made contact with the disease’s bacteria plausible. Therefore, the illness was acquired during and due to his employment. The award of P6,000.00 as compensation, attorney’s fees, and administrative fees was sustained.